Hinsa Virodhak Sangh v. Mirzapur Moti Kuresh Jamat (2008)

This case looks at a short, festival-time restriction on slaughterhouses in Ahmedabad. Traders said it hurt their right to trade under Article 19(1)(g) and affected meat eaters’ Article 21 rights.

The Supreme Court held that a limited, nine-day closure is a reasonable and proportionate restriction under Article 19(6). But a long or sweeping closure would be excessive and likely unconstitutional.

• Does a short meat-production restriction violate Article 19(1)(g) without protection of Article 19(6)?
• Does the restriction affect the Article 21 right to life of regular meat consumers?

Held: A nine-day closure is a partial, time-bound restriction. It is reasonable and not disproportionate under Article 19(6).

But a longer or extensive closure would be excessive: it could harm livelihoods in the meat trade and force diets on non-vegetarians in Ahmedabad, making it unconstitutional.

Thus, narrow tailoring and short duration saved the measure; sweeping restrictions would fail.

• Reasonableness under Article 19(6) depends on duration, scope, and impact on trade and public.
• Short, festival-time restrictions can be valid; long bans risk being disproportionate.
• Article 21 concerns arise if policies effectively compel lifestyle change or threaten livelihood at scale.

The case sets a proportionality guide for temporary civic restrictions that touch food choices and trade. Governments must keep measures limited, justified, and time-bound.

Mnemonic: D-S-P — Duration • Scope • Public impact.

1. Time: Is it brief and announced?
2. Target: Is it narrow (not a blanket ban)?
3. Effect: Does it protect interest without crushing jobs or choice?

Article 19(1)(g)

Right to carry on trade or business.

Article 19(6)

Allows reasonable restrictions in public interest.

Article 21

Protection of life and personal liberty.

Proportionality

A measure must fit the goal without excessive harm to rights.